A/HRC/31/18 Rabat Plan of Action, “many blasphemy laws afford different levels of protection to different religions and have often proved to be applied in a discriminatory manner. There are numerous examples of persecution of religious minorities or dissenters, but also of atheists and non-theists, as a result of legislation on what constitutes religious offences or overzealous application of laws containing neutral language” (para. 19). Based on that assessment, it recommends that “States that have blasphemy laws should repeal them, as such laws have a stifling impact on the enjoyment of freedom of religion or belief, and healthy dialogue and debate about religion” (para. 25). Moreover, blasphemy provisions may encourage non-State actors to threaten and commit acts of violence against people expressing critical views. 61. Obviously, satirical comments on religious issues or depictions of religious figures may sometimes offend the feelings of believers. Those who feel offended are free to voice their anger publicly and call for a change in attitudes. This can also become an issue for interreligious communication and public debates. Subjective feelings of offensiveness, however, should never guide legislative action, court decisions or other State activities. The threshold for imposing legal restrictions on freedom of expression must remain very high, in compliance with the criteria provided in international human rights law. At the same time, there is still space for other. non-restrictive, activities. For instance, the media may establish voluntary mechanisms of religious sensitization. In general, sensitivity concerning the religious sentiments of different religious and belief communities should become an important feature of a culture of communication, especially in multi-religious societies. However, the employment of criminal sanctions against expressions which do not advocate for violence or discrimination but which are deemed “blasphemous” cannot play a productive role in such endeavours, and such criminal sanctions, wherever they exist, are incompatible with the provisions of freedom of religion or belief and freedom of expression. 2. Unclear anti-hatred laws 62. While legal sanctions must not be employed to protect the religions or beliefsystems per se against adverse comments, such sanctions may be necessary to protect human beings against incitement to acts of hatred, as reaffirmed in Human Rights Council resolution 16/18 and the Rabat Plan of Action. Indeed, article 20 (2) of the Covenant explicitly calls upon States to prohibit any advocacy of religious hatred that constitutes incitement to discrimination, hostility or violence, which implies, inter alia, adopting adequate legislation. 63. However, State practices in this regard vastly differ and often reveal a lack of consistency. Sometimes failure to act on “real” incitement cases, on the one hand, and overzealous reactions to innocuous cases, on the other, exist simultaneously, thus creating a climate of impunity for some and a climate of intimidation for others. The Rabat Plan of Action notes: It is of concern that perpetrators of incidents, which indeed reach the threshold of article 20 of the International Covenant on Civil and Political Rights, are not prosecuted and punished. At the same time members of minorities are de facto persecuted, with a chilling effect on others, through the abuse of vague domestic legislation, jurisprudence and policies (para. 11). In practice, this often leads to the non-prosecution of perpetrators belonging to the State religion and to the persecution of members of religious minorities under the guise of antiincitement laws. 64. Domestic laws which prohibit incitement to hatred are often vaguely defined, thus failing to meet the requirements contained in articles 18 (3), 19 (3) and 20 (2) of the 17